An Bord Pleanala has already ruled that the project can be decided under its fast-track process available to schemes of national importance.
However, voluntary group Dublin Bay Watch (DBW) has come out against the plans.
In a submission lodged with An Bord Pleanala, DBW said it does not accept the port company's contention that there is a capacity issue at the facility.
The group added: "It is submitted that the development should be refused on the basis that there are no zoning, policy or other objectives in the Dublin City Development Plan 2005-2011 supporting the infill of 52 acres and a further approximate 53 acres of dredging."
DBW, whose chairman is Fine Gael councillor Gerry Breen, dismissed the idea that the community will gain from the project.
"Dublin Bay Watch is of the view that there is no gain for the community in the proposal by the Dublin Port Company to transfer land on the Bull Island to Dublin City Council," the submission stated.
"This is not appropriate compensation for the loss of over 100 acres of a proposed SPA (Special Protection Area). It is our understanding the offer has previously been turned down by the council and raising it in the context of the proposed application is mischievous," it added.
Dublin Port has said the "52-acre expansion of the north port area will provide much needed additional capacity".
"This development will cater for greater demand as a result of the projected increases in population. Dublin Gateway will also provide deeper berths that will enable Dublin Port to cater for the international trend towards larger, more efficient vessels that require deeper water to operate," said the firm.
"As part of the application process, Dublin Port Company has completed an extensive planning application including an Environmental Impact Statement which will be submitted to An Bord Pleanala and circulated to a number of prescribed organisations."
An Bord Pleanala had decided the plan represented a strategic infrastructural development, thereby allowing it to be heard under its fast-track process.
The development plans for the construction of new quays to the south and east of the site at the north bay near Clontarf promenade. If the proposal is given the go ahead, three new berths for roll-on, roll-off ferries will be built on the southern quay and a fourth berth for load-on, load-off ferries will be provided on the eastern quay.